Sculpture N.V.
CGA/2025/2453/1316
GrantedCustomer
- Contact
- Glenn C. Rellum
- sculpture-gm-clients@decc-management.com
- Company
- Sculpture N.V.
Review Timeline
MMMarilisa Mathew (CGA User 1)
AAAnton Axiaq (AAX)
MMMarilisa Mathew (CGA User 1)
AAAnton Axiaq (AAX)
STSarah Tua (ST)
MMMarilisa Mathew (CGA User 1)
AAAnton Axiaq (AAX)
STSarah Tua (ST)
AAAnton Axiaq (AAX)
HSHilary Stewart Jones (HSJ)
MMMarilisa Mathew (CGA User 1)
LCLuca Camilleri (LC)
LCLuca Camilleri (LC)
HSHilary Stewart Jones (HSJ)
GHGisah Hollander (GH)
CPCedric Pietersz (Managing Director GCB)
Compliance Checklists
Phase 1Critical15 items
Please note that the name and digital signature on the Declaration and Data Privacy page must be those of the Managing Director. Kindly correct this and resubmit the form.
Please note that the name and digital signature on the Declaration and Data Privacy page must be those of the Managing Director. Kindly correct this and resubmit the form.
Please note that the managing director cannot certify the share ledger. Kindly submit a certified true copy of the share ledger that is certified by an independent and authorized certifier.
Please note that the managing director cannot certify the share ledger. Kindly submit a certified true copy of the share ledger that is certified by an independent and authorized certifier.
Questions 8 and 9 have been left blank. Question 11.1 indicates that the company will be funded through shareholder loans. Please clarify as to where the company will be receiving the funds from the loan.
Questions 8 and 9 have been left blank. Question 11.1 indicates that the company will be funded through shareholder loans. Please clarify as to where the company will be receiving the funds from the loan.
Please note that the loan agreement must be certified as a true copy. Kindly submit a certified copy of the loan agreement.
<p>Please note that the loan agreement must be certified as a true copy. The loan agreement must also be signed by the managing director. Kindly submit a fully executed certified copy of the loan agreement.</p><p><b><u>UPDATE:</u></b></p><p>Please note that <u>the passport number of the lender (Zyrelle M.J. Raymundo) indicated in the loan agreement does not match her current passport</u>. </p><p>Please correct the passport number and resubmit a certified copy of the loan agreement.</p>
Please note that the Personal History Disclosure Short Form uploaded for Glenn Rellum is the old GCB form and cannot be accepted. Kindly complete and upload the new CGA Personal History Disclosure Short Form.
Please note that the Personal History Disclosure Short Form uploaded for Glenn Rellum is the old GCB form and cannot be accepted. Kindly complete and upload the new CGA Personal History Disclosure Short Form.
Please note that incorrect information was entered for this question. Kindly enter the email address and resubmit the form.
Please note that incorrect information was entered for this question. Kindly enter the email address and resubmit the form.
Please add Dragon Money N.V. to the answer in question 7.1 and resubmit the form.
<p>Please add Dragon Money N.V. to the answer in question 7.1 and resubmit the form.</p><p><b><u>UPDATE</u></b></p><p>Please note that Dragon Money B.V. was entered, but the correct company name is Dragon Money N.V. Please correct the company name and resubmit the form.</p>
Please note that the date of expiry of the passport is incorrect. Kindly enter the correct date and resubmit the form.
Please note that the date of expiry of the passport is incorrect. Kindly enter the correct date and resubmit the form.
Please note that the address on the proof of address document does not match the current address entered on the Personal History Disclosure Form. Kindly provide a proof of address document for the address listed on the Personal History Disclosure Form. If the person now resides at another address, this must be updated on the Personal History Disclosure Form.
Please note that the address on the proof of address document does not match the current address entered on the Personal History Disclosure Form. Kindly provide a proof of address document for the address listed on the Personal History Disclosure Form. If the person now resides at another address, this must be updated on the Personal History Disclosure Form.
Please provide further supporting documentation of Source of Wealth. Kindly note that all documents must be no more than 6 months old and must be certified as a true copy.
Please provide further supporting documentation of Source of Wealth. Kindly note that all documents must be no more than 6 months old and must be certified as a true copy.
Submit financial statements for years ending 2023 and 2024, as well as signed financials in whatever form which are not older than 6 months
<p>Submit financial statements for years ending 2023 and 2024, as well as signed financials in whatever form which are not older than 6 months</p><p><b><u>UPDATE</u></b></p><p>Please note that <b>no financial statements were found in the portal</b>. Please upload the signed financial statements for 2023, 2024 and 2025 (in whatever form), in the Compiled Financial Statements section under Business and Corporate Information Form - Enclosures.</p>
Please note that the Personal History Disclosure Short Form must be dated within six months of today's date. Kindly update the date on the form and resubmit it.
Please note that the Personal History Disclosure Short Form must be dated within six months of today's date. Kindly update the date on the form and resubmit it.
Please note that 'Yes' must be selected for question 7 and question 7.1 must be completed. In question 7.1, please indicate that you are a CSP/managing director involved with many other granted Curaçao Gaming Licenses. Kindly complete questions 7 and 7.1 and resubmit the form.
Please note that 'Yes' must be selected for question 7 and question 7.1 must be completed. In question 7.1, please indicate that you are a CSP/managing director involved with many other granted Curaçao Gaming Licenses. Kindly complete questions 7 and 7.1 and resubmit the form.
Please note that an incorrect application number was entered. Kindly enter the correct application number and resubmit the form.
Please note that an incorrect application number was entered. Kindly enter the correct application number and resubmit the form.
Please note that the application date is more than six months old. Kindly update the application date and resubmit the form.
Please note that the application date is more than six months old. Kindly update the application date and resubmit the form.
Phase 1 - Due DiligenceCritical8 items
The Declaration of Good Standing of Sculpture N.V. was not provided. Kindly submit the requested Declaration of Good Standing (verzoek verklaring betalingsgedrag) in the Extra Documentation section and name the file Declaration of Good Standing. Please note that the Declaration of Good Standing must be the document issued by the Tax Authorities and have the stamp of 'ontvanger' and the 'invorderaar'. If the document is not in English, a certified English translation must also be submitted together with the original document.
<p>The Declaration of Good Standing of Sculpture N.V. was not provided. Kindly submit the requested Declaration of Good Standing (verzoek verklaring betalingsgedrag) in the Extra Documentation section and name the file Declaration of Good Standing. </p><p>Please note that the Declaration of Good Standing must be the document issued by the Tax Authorities and have the stamp of 'ontvanger' and the 'invorderaar'. If the document is not in English, a certified English translation must also be submitted together with the original document.</p>
Please note that the bank reference letter must reference the person's standing at the bank. Kindly provide a new bank reference letter to this effect, also ensuring that the bank reference letter is certified and was issued within the last six months.
Please note that the bank reference letter must reference the person's standing at the bank. Kindly provide a new bank reference letter to this effect, also ensuring that the bank reference letter is certified and was issued within the last six months.
Please note that the CV of Kateryna Veremiienko is missing. Please upload the CV in the base application QPA 2024/02757 in the letter of engagement section.
<p>Please note that the CV of Kateryna Veremiienko is missing. </p><p>Please upload the CV in the <b><u>base application QPA 2024/02757 in the letter of engagement section</u></b>.</p>
Please note that the letter of engagement uploaded for Kateryna Veremiienko is no longer valid as the contract expired on April 30, 2025. Please upload a new letter of engagement that is signed by both the compliance officer and the managing director.
Please note that the letter of engagement uploaded for Kateryna Veremiienko is no longer valid as the contract expired on April 30, 2025. Please upload a new letter of engagement that is signed by both the compliance officer and the managing director.
Please note that the answer to question 43 is missing. Please complete question 43 and resubmit the form.
Please note that the answer to question 43 is missing. Please complete question 43 and resubmit the form.
Please note that the Personal History Disclosure Form uploaded in the base application (QPA/2024/02757) is the old GCB form. Please upload the new CGA Personal History Disclosure Form (long form) available on the website in the base application QPA/2024/02757.
<p>Please note that the <b><u>Personal History Disclosure Form uploaded in the base application (QPA/2024/02757) is the old GCB form</u></b>. </p><p>Please upload the <b><u>new CGA Personal History Disclosure Form (long form)</u></b> available on the website in the <u><b>base application QPA/2024/02757</b></u>.</p>
1. Submit FS from the date of incorporation until year ending 2024 2. Submit signed financials in whatever form for the FSM 2025 3. Submit a recent and certified balance statement of the company's wallet
1. Submit the FS of the applicant company from the date of incorporation until year ending 2024 2. Submit signed financials in whatever form for the FSM 2025 3. Submit recent and certified documentation evidencing any cypto balances owned by the applicant
Clarity how the UBO intends to manage any conflicts between her full time employment and the applicant company
Clarify how the UBO intends to manage any conflicts between her full time employment and the applicant company
Phase 2Critical2 items
Please upload the Know Your Customer Policy, in the designated policy section.
Please upload the Know Your Customer Policy, in the designated policy section.
Please upload the Information Security Policy, in the designated policy section.
Please upload the Information Security Policy, in the designated policy section.
AML PolicyCritical9 items
The policy must be signed by the Compliance Officer and Managing Director of the applicant.
The policy must be signed by the Compliance Officer and Managing Director of the applicant.
The policy must identify the office responsible for updates and review of the policy.
The policy must identify the office responsible for updates and review of the policy.
The policy must state that it will be reviewed periodically, at minimum, once a year.
The policy must state that it will be reviewed periodically, at minimum, once a year.
The policy must make reference to Curacao laws, specifically the following: LOK, NORUT, NOIS, CGA Guidelines, Sanctions Ordinance and Criminal Code.
The policy must make reference to Curacao laws, specifically the following: LOK, NORUT, NOIS, CGA Guidelines, Sanctions Ordinance and Criminal Code.
The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.
The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.
The operator must conduct a Customer Risk Assessment which will assess the particular risks the casino will be exposed to when providing its services or products to players. The information collected to draw up the CRA will formulate the customer's risk profile. The customer specific risk assessment has to be carried out during establishing a business relationship. The categories follow from the BRA.
The operator must conduct a Customer Risk Assessment which will assess the particular risks the casino will be exposed to when providing its services or products to players. The information collected to draw up the CRA will formulate the customer's risk profile. The customer specific risk assessment has to be carried out during establishing a business relationship. The categories follow from the BRA.
On the basis of the CRA, the AML & KYC Policy must include a Customer Acceptance Policy, on which the proper level of CDD can then be applied. When drawing up its CAP the casino has to comply with its obligations with regard to Politically Exposed Persons (PEP) and Sanctions Screening. The CAP should address the type of players that pose higher than average risk and also indicate the circumstances under which a player is denied.
On the basis of the CRA, the AML & KYC Policy must include a Customer Acceptance Policy, on which the proper level of CDD can then be applied. When drawing up its CAP the casino has to comply with its obligations with regard to Politically Exposed Persons (PEP) and Sanctions Screening. The CAP should address the type of players that pose higher than average risk and also indicate the circumstances under which a player is denied.
The policy must define the rules and risk controls around virtual assets and crypto usage.
The policy must define the rules and risk controls around virtual assets and crypto usage.
The policy must outline the annual audit plan of the AML program and internal controls.
The policy must outline the annual audit plan of the AML program and internal controls.
KYC PolicyCritical3 items
The policy must state that players who do not register themselves will not be allowed to play.
The policy must state that players who do not register themselves will not be allowed to play.
The policy must provide for name screening against sanctions lists to be carried out prior to the onset of the business relationship and at determinate points in time afterwards, the procedure to be adopted in carrying out sanctions screening and the sources used for such purpose.
The policy must provide for name screening against sanctions lists to be carried out prior to the onset of the business relationship and at determinate points in time afterwards, the procedure to be adopted in carrying out sanctions screening and the sources used for such purpose.
The policy must lay down the procedure to be adopted to ensure that any player related documents, data or information held by the Licensee are reviewed and kept up-to-date.
The policy must lay down the procedure to be adopted to ensure that any player related documents, data or information held by the Licensee are reviewed and kept up-to-date.
Responsible Gaming PolicyCritical5 items
The RG policy must outline the procedure for post-registration account closure upon the operator becoming aware that the player is a minor.
The RG policy must outline the procedure for post-registration account closure upon the operator becoming aware that the player is a minor.
The RG policy must state the operator's record-keeping policy.
The RG policy must state the operator's record-keeping policy.
The RG policy must describe the procedure for how the player can contact the operator regarding RG concerns via email or chat.
The RG policy must describe the procedure for how the player can contact the operator regarding RG concerns via email or chat.
The options for cooling-off may include duration, brand, vertical and marketing, of which the duration and marketing opt-out are mandatory.
The options for cooling-off may include duration, brand, vertical and marketing, of which the duration and marketing opt-out are mandatory.
Operators may employ automatic or pop-up notifications in response to concerning behaviours.
Operators may employ automatic or pop-up notifications in response to concerning behaviours.
Player Complaints PolicyCritical4 items
The policy must state that players may lodge a complaint free of charge at any time up to six months of the settlement of the bet or the incident about which they are making a complaint.
The policy must state that players may lodge a complaint free of charge at any time up to six months of the settlement of the bet or the incident about which they are making a complaint.
The policy must state that in the case of complaints about in-running sports betting, customers must be advised that while they may submit a complaint within six months, prompt action may be necessary if the investigation may depend on data specific to the complaint which — due to the nature of in-running betting.
The policy must state that in the case of complaints about in-running sports betting, customers must be advised that while they may submit a complaint within six months, prompt action may be necessary if the investigation may depend on data specific to the complaint which — due to the nature of in-running betting.
The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity.
The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity.
The policy must state that in the event that the player drops out of the ADR process (but it has already begun) the player should not have the right to resurface the dispute in the future.
The policy must state that in the event that the player drops out of the ADR process (but it has already begun) the player should not have the right to resurface the dispute in the future.